G/SG/N/8/TUR/20  
G/SG/N/10/TUR/20  
G/SG/N/11/TUR/27  
 
5 August 2022  
(22-5845) Page: 1/9 
Committee on Safeguards  Original: English  
 
 
NOTIFICATION UNDER ARTICLE 12.1(B) OF THE AGREEMENT  
ON SAFEGUARDS ON FINDING A SERIOUS INJURY OR THREAT  
THEREOF CAUSED BY INCREASED IMPORTS  
 
NOTIFICATION PURSUANT TO ARTICLE 12.1(C)  
OF THE AGREEMENT ON SAFEGUARDS  
 
NOTIFICATION PURSUANT TO ARTICLE 9, FOOTNOTE 2  
OF THE AGREEMENT ON SAFEGUARDS  
TÜRKIYE  
Grinding balls and similar articles for mills  
The following notification, dated and received on 4 August 202 2, is being circulated at the request 
of the delegation of Türkiye . 
 
______ _________  
 
 
Concerning imports of grinding balls and similar articles for mills, Türkiye had notified the initiation 
of a safeguard investigation with the WTO Document G/SG/N/6/TUR/28, dated 13  October  2021.  
 
Türkiye hereby provides notification to the Committee on Safeguards of findings of serious injury or 
threat thereof caused by increased imports and notification of a proposed definitive safeguard 
measure. The public version of the investigation report (in Turkish) together with r eferences and 
sources can be found at the following internet addresses below.  
 
https://www.resmigazete.gov.tr/eskiler/2022/07/20220727 -20.htm  
 
Consistent with Article 12.3 of th e Agreement on Safeguards , Türkiye is prepared to consult with 
those Members having a substantial interest as exporters of the product concerned.  
 
I. EVIDENCE OF SERIOUS INJURY OR THREAT THEREOF CAUSED BY INCREASED 
IMPORTS  
A. Evidence of ser ious injury  
In order to make a determination of serious injury or threat thereof to the domestic producers of 
the like product, an evaluation of all relevant factors of an objective and quantifiable nature having 
a bearing on the situation of the domestic industry was undertak en. The data, which were submitted 
by the applicant companies and utilized in this analysis, represent major proportion of the total 
domestic production of the product subject to investigation.  
 
1. Consumption  
Unit (Tons)  2017  2018  2019  2020  2020 
(9) 2021 
(9) 
Consumption 
(Indexed)  100 105 125 137 100 103 G/SG/N/8/TUR/20 • G/SG/N/10/TUR/20 • G/SG/N/11/TUR/27  
 
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Consumption index rose during the period under consideration (PUC). In 2020, consumption reached 
its peak which is 37% higher than its level in 2017.  
 
2. Production  
Unit (Tons)  2017  2018  2019  2020  2020 
(9) 2021 
(9) 
Production (Indexed)  100 151 181 216 100 69 
 
Production index increased continuously during the PUC. Production level increased by 116% from 
2017 to 2020. The index decreased by 31% in the first 9 months of 2021, compared to the same 
period of 2020.  
 
3. Domestic Sales  
Unit (Tons)  2017  2018  2019  2020  2020 
(9) 2021 
(9) 
Domestic Sales 
(Indexed)  100 107 127 139 100 89 
 
Domestic sales index continuously increased during the PUC. It rose to 139 as its highest point in 
2020. The index decreased by 11% in the first 9 months of 2021, compared to the same period of 
2020.  
 
4. Capacity and Capacity Utilization Ratio (CUR)  
Unit (Tons)  2017  2018  2019  2020  2020 (9)  2021 (9)  
Capacity (Indexed)  100 194 194 194 100 100 
CUR (%) (Indexed)  100 78 93 111 100 69 
 
Production capacity increased throughout the PUC and the index reached 194 in 2018. Capacity 
utilization ratio (CUR) index declined in 2018 and increased in 2019 and 2020. The index decreased 
by 31% in the first 9 months of 2021, compared to the same period of 2020.  
 
5. Inventories  
Unit (Tons)  2017  2018  2019  2020  2020 (9)  2021 (9)  
Stocks  (Indexed)  100 483 521 1006 100 46 
 
During the PUC, inventory index continuously increased and reached 1006 in 2020. In particular, 
the inventory indicator marked a rapid increase in 2018. The rise in inventories continued in 2020.  
 
6. Employment  
Workers  2017  2018  2019  2020  2020 
(9) 2021 
(9) 
Employment  (Indexed)  100 99 102 109 100 109 
 
Employment index showed an ascending pattern throughout the PUC (with the exception of 2018).  
 
7. Labor Productivity  
Unit (Tons)  per 
Worker  2017  2018  2019  2020  2020 
(9) 2021 
(9) 
Productivity (Indexed)  100 152 177 198 100 63 G/SG/N/8/TUR/20 • G/SG/N/10/TUR/20 • G/SG/N/11/TUR/27  
 
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Labor productivity index displayed an ascending pattern between 2017 and 2020. The index 
decreased by 37% in the first 9 months of 2021, compared to the same period of 2020.  
 
8. Profitability  
Net Profit/Total Sales  2017  2018  2019  2020  2020 (9)  2021 (9)  
Profitability (Indexed) 
(%) 100 -37 -41 52 100 -350 
 
Profitability was negative throughout the PUC exception of year 2020. Domestic industry incurred 
loss from the sales of the product concerned in the first 9 months of 2021.  
 
9. Exports  
Unit (Tons)  2017  2018  2019  2020  2020 
(9) 2021 
(9) 
Exports (Indexed) (%)  100 297 472 559 100 73 
 
Exports of domestic industry increased considerably throughout the PUC. Exports index reached 559 
in 2020. The index decreased by 27% in the first 9 months of 2021, compared to the same period 
of 2020.  
10. Conclusion  
When the economic indicators of the domestic industry are examined, it is seen that the grinding 
balls consumption in Türkiye has increased continuously throughout the PUC. Under these market 
conditions, the domestic industry recorded an increas e in its production capacity in 2017, in line with 
the growth in consumption. In this regard, the market share of the domestic industry increased to 
X% in 2020, the highest level of the PUC. The import of grinding balls, which is the subject of the 
investi gation, increased significantly during the investigation period. Imports, which increased by 
29% on quantity basis from 2017 to 2020, increased significantly by 59% in the 9 -month period of 
2021 compared to the same period of the previous year. Despite the  problems experienced in 
international supply conditions due to the impact of the Covid -19 epidemic, imports did not decrease 
in 2020, and as the epidemic conditions began to change, an increase was observed in general 
imports in the January -September peri od of 2021 with low unit prices and imports from nearby 
countries, and this increase is expected to continue with economic normalization.  
 
In addition, the domestic producers increased its production capacity in 2017 in parallel with the 
expansion in domes tic consumption. However, the domestic producers could not increase its 
domestic market share during the investigation period, due to the increase in imports from sources 
with low unit prices, on the contrary, the market share of the domestic producers dec reased 
significantly in the 9 -month period of 2021. However, in order to maintain its position in the market, 
it had to reduce sales prices and work with -X% profitability. Again, this year, the capacity utilization 
rate remained far from the sustainable l evel.  
 
In this context, significant deteriorations are observed on the domestic producers ' indicators 
especially at the end of the PUC when there is a sharp surge in imports. Taking into account all these 
factors, it is concluded that the domestic industr y as a whole is exposed to serious injury for the 
product concerned.  
 
B. Causat ion Analys is 
In order to examine the existence of a causal link between increased imports and the serious injury 
or threat thereof and in order to ensure that injury caused by other factors is not attributed to 
increased imports, the investigating authority analyzed the effects of the following factors:  
 G/SG/N/8/TUR/20 • G/SG/N/10/TUR/20 • G/SG/N/11/TUR/27  
 
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  1. Analysis of Causation Factors  
(a) Effect of Increased Imports  
Imports of the product concerned increased constantly during the PU C. From 2018 to 2020 period 
increase rate in imports was 18%, 12% respectively. In 2021 9 months this rate of increase was 
60% with respect to the previous year 's same 9 months period.  
Likewise, the market share of imports increased by 7% between 2017 and  2021 and domestic 
industry lost significant market share. Therefore, it is concluded that the increase in imports and the 
deterioration in the economic indicators of the domestic industry followed a similar pattern 
throughout the period analyzed.  
 
In con clusion, it is inferred that there is a correlation between the increase in imports and threat of 
serious injury that the domestic industry is exposed to.  
 
(b) Conditions of Competition  
Although there are some differences in production methods, cast and forged  balls are substitute 
products. When one product increases its performance and the other lowers its price, they can get 
market share from each other and can be directly substituted.  
 
Imported and local grinding ball products can be used interchangeably and show similarities in terms 
of physical -chemical properties and production technologies. According to the information obtained 
during the investigation, the investigation authority concluded that price of the product was the most 
signifi cant factor for user preference in the domestic market. In this respect, it is evident that price 
level directly determines the sales volumes of domestic and imported goods. When these factors are 
taken into consideration, the domestically produced product  and the imported product are 
considered as like or directly competitive products.  
 
Unit Price Comparison (USD/Kilograms)  2017  2018  2019  2020  2020 
(9) 2021 
(9) 
Unit Domestic Ex -Works Sales Price of the 
Domestic Product  X X X X X X 
Constructed Unit Price of the Domestic 
Product (Unit Commercial Cost + 5% Profit 
Margin)  X X X X X X 
Weighted Average Cost of the Imported 
Product  1,05 1,16 1,1 1,03 1,05 1,07 
Price Undercutting  -X -X -X -X -X X 
Price Suppression  -X -X -X -X -X X 
 
When the imported unit costs of the products under investigation are compared with the unit 
domestic sales prices of the domestic product, it is seen that the unit costs of imported products are 
below the domestic sales prices of domestic products in 2021. In this framework, despite there is 
no price undercutting in 2017 -2020 period, within the line of  import increase, the price undercutting 
ratios calculated X % for 2021 9 months period. On the other hand, it has been observed that 
imports from Iran and Egypt, whic h are among the most important suppliers whose carry an logistic 
advantages , have recently undercut the prices of domestic producers.  
 G/SG/N/8/TUR/20 • G/SG/N/10/TUR/20 • G/SG/N/11/TUR/27  
 
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  (c) Coinciding Trends  
It is understood that there is parallelism between all the relevant factors of an objective and 
quantifiable nature having a bearing on the situation of the domestic industry such as the decline in 
profitability, decrease in the capacity utilization ratio and the increase in the imports of the product 
concerned in absolute and relative terms together  with the rise in the market share of the imports.  
(d) Other Factors  
(i) Production capacity of domestic producers  
The grinding ball production capacity of the domestic industry was X thousand tons in 2017 and 
increased to X thousand tons in 2018. First of all, it  is seen that the domestic consumption of the 
product under investigation has been following a constantly increasing trend in the period under 
review, and the capacity increase made in this context is in line with the domestic market conditions. 
In additio n, despite the capacity increase, the market share of the domestic production branch did 
not change significantly between 2017 and 2020, and domestic producers experienced a significant 
loss of market share against imports in the 9 -month period of 2021. In  this respect, it has been 
evaluated that the deterioration in economic indicators has not been caused by the losses due to 
capacity increase, and that the increase in capacity does not have an effect on the serious injury.  
 
(ii) Production Technology of the Do mestic Producers  
During the investigation, some interested parties claimed that the domestic producers could not 
compete with imported products in terms of quality. However, not only the findings from on the spot 
investigations but also other documents sub mitted by the interested parties throughout  the 
investigation reveal that the production technologies of the domestic producers are broadly identical 
with that of the exporter companies. In this respect, the domestic producers manufacture the 
products in a  large variety. As a result, it appears that technology did not play a role in the threat 
of serious injury that the domestic industry has been facing.   
 
2. Conclusion on Causation  
From 2017 to 2020, the quantities of imports increased significantly at the ra te of 34%. In this 
framework, having concluded that there is a correlation between the increase in imports and the 
serious injury that the domestic industry has been facing; having examined the effects of other 
known factors and having determined that no i njurious effects resulted from these; the investigating 
authority reached to the conclusion that there is a causal link between increased imports and the 
serious injury that the domestic industry has been exposed to.  
 
II. INFORMATION ON WHETHER THERE IS AN ABS OLUTE INCREASE IN IMPORTS OR 
AN INCREASE IN IMPORTS RELATIVE TO DOMESTIC PRODUCTION  
1. Unforeseen Developments  
Global Exports of the Main Supplier Countries  
  2017  2018  2019  2020  2021  2017 -2021  
Country  Tons  Tons  Tons  Tons  Tons  % ∆ 
P.R.C.  741.578  821.833  847.744  828.139  826.826  11% 
India  154.750  189.250  180.965  198.770  181.364  17% 
Chile  169.614  127.562  128.982  98.743  111.777  -34% 
Thailand  79.249  87.875  88.792  85.305  97.694  23% 
U.S.A  95.483  88.451  101.112  59.714  84.288  -12% G/SG/N/8/TUR/20 • G/SG/N/10/TUR/20 • G/SG/N/11/TUR/27  
 
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  Russia  38.645  46.305  47.485  52.391  66.273  71% 
Spain  77.033  75.670  56.386  57.080  64.562  -16% 
South Africa  44.226  40.503  32.656  33.917  44.003  -1% 
Australia  39.365  29.235  25.452  20.196  17.601  -55% 
Poland  14.184  14.256  17.415  15.508  17.364  22% 
 
When the export data of the main supplier countries are evaluated, it is seen that China was the 
largest exporter country in the world in terms of quantity between 2017 and 2021. In addition, it is 
understood that India maintained its position as the second lar gest supplier in the 2017 -2021 period. 
Furthermore, it is noted that Thailand has increased its exports significantly in this 5 -year period.  
 
It is noteworthy that Thailand recorded an aggressive increase in the export of the product under 
investigation, i ncreasing its exports to the world by more than 20% between 2017 and 2021, and 
came to the fore among the top 5 exporters at the rate of increase. The period in question 
corresponds to the period in which Thailand's exports to Türkiye increased nearly four  times. The 
global total exports of the aforementioned goods decreased in the 2019 -2020 period due to the 
problems arising in the international supply channels and the logistics sector due to the impact of 
Covid -19, and the increases in raw material and fr eight prices. On the other hand, Türkiye's imports 
of the products under investigation increased in the same period, and Thailand is the country with 
the highest supplier country, but there has also been a change in the country composition.  
 
In this period , the increase in imports from Egypt and Iran, which are located in close geographical 
locations, is remarkable. Iran has recently increased its capacity in steel ball production, and it is 
seen that the total production in the country is much higher than the demand in the country. 
Additionally, the low natural gas costs in Iran put them in an advantageous position in the world 
market in terms of steel product exports.  
 
In this context, the increase in the world exports of the product covered by the investigation, the 
increase in the production capacities and exports of the supplier countries with relatively low unit 
prices, accordingly the export from the said countries to Türkiye are evaluated as unforeseen 
developments that led to an increase in imports of the product under investigation.  
 
In the light of the above evaluations, the investigating authority concluded that the recent 
unforeseen developments in the world m arket led to a surge in imports of the product concerned 
during the investigation period.  
 
2. Increase in Imports  
An analysis of the increase in imports into Türkiye of the product concerned in absolute terms was 
carried out over the period from 2017 to Janua ry-September of 2021. Imports of the product 
concerned increased considerably, in absolute terms during the period of investigation.  G/SG/N/8/TUR/20 • G/SG/N/10/TUR/20 • G/SG/N/11/TUR/27  
 
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  a) General View of Imports  
IMPORTS  Quantity  Value  Unit Price  Change  
Period  Kg $ ($/Kg)  Kg $ ($/Kg)  
2017  4.962.872  5.068.275  1,02 - - - 
2018  4.884.137  5.514.585  1,13 -%2 %9 %11 
2019  5.743.519  6.124.285  1,07 %18 %11 -%6 
2020  6.438.673  6.474.473  1,01 %12 %6 -%6 
2020 (9)  4.180.353  4.264.233  1,02 - - - 
2021 (9)  6.676.893  6.956.513  1,04 %60 %63 %2 
 
It is observed that the import amount of the product under investigation has followed an increasing 
course between 2018 and 2020 on the basis of quantity and value. Especially in the first 9 months 
of 2021, there is a significant increase in imports compared to the same period of 2020. In this 
context, when evaluated as a whole, it is observed that imports generally increased during the 
investigation period, and there was a sudden and sharp increase in the 9 -month period of 2021. 
However, the average unit price o f imported products followed a fluctuating course throughout the 
investigation period and fell to the lowest level in 2020.  
 
b) Absolute Imports  
Imports  
(Tons)  2017  2018  2019  2020  2020 
(9) 2021 
(9) 
4.963  4.884  5.774  6.439  4.180  6.667  
 
Imports of the product concerned increased considerably during the period analyzed.  Additionally, 
imports grew by 60% in the first 9 -month period of 2021 compared with the same period of 2020.   
 
c) Relative Imports  
Imports/Production  
 (% – Index)  2017  2018  2019  2020  2020 (9)  2021 (9)  
100 65 64 60 100 231 
 
The ratio of imports to domestic production rose in 2021 to the highest level of 231.  
 
d) Market Share of Imports  
Market Share of Imports  
(% – Index)  2017  2018  2019  2020  2020 
(9) 2021 
(9) 
100 94 93 95 100 155 
 
The market share of the imported products decreased from 2017 to 2019 and then increased in the 
next period. In the first 9 months of 2021, it increased to the level of 155.  
 
III. PRECISE DESCRIPTION OF THE PRODUCT INVOLVED  
The subject product is classified und er Turkish Customs Codes 7325.91.00.00.00 and 
7326.11.00.00.00  in Turkish Customs Tariff Schedule of 2022.  G/SG/N/8/TUR/20 • G/SG/N/10/TUR/20 • G/SG/N/11/TUR/27  
 
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IV. DESCRIPTION OF THE PROPOSED MEASURE  
The imposition of a definitive safeguard measure is proposed in the form of specific duty per tons, 
which will be implemented as shown in the table below.  
 
Customs Tariff 
Statistics Code  Definit ion Proposed Measure  
1st Year  2nd Year  3rd Year 
7325.91.00.00.00  Grinding balls and similar articles 
for grinding  200 
USD/Tons  195 
USD/Tons  190 
USD/Tons  
7326.11.00.00.00  Grinding balls and other articles 
for grinding  
 
Below is the list of developing countries excluded from the measure, according to Article 9.1 of the 
Agreement on Safeguards , as they constitute less than 3% individually and 9% collectively of 
imports of Türkiye. The exemption will be applied in the form of tariff quotas. To that end, each 
country will be granted, for each period, a tariff quota of 347 tons, the amount that represents 3% 
of imports of Türkiye of the product concerned in the year 2020. Overall, total amount of tariff quota 
shall not exceed 1.040 tons, 9% of total imports of Türkiye in 2021.  
 
Afghanistan, Angola, Antigua and Barbuda, Argentina, Albania, Azerbaijan, Bangladesh, Barbados, 
Belarus, Belize, Benin, Bolivia (Plurinational State Of) , Bosnia and Herzegovina, Botswana, Brazil, 
Burkin a Faso, Burundi, Bhutan, Algeria, Djibouti, Cook Islands, Chad, Democratic Republic of Congo, 
Dominican Republic, Dominica, Equator, Equatorial Guinea, El Salvador, Indonesia, Eritrea, Ethiopia, 
Morocco, Fiji, Côte D'Ivoire, Philippines, Palestine, French Polynesia, Gabon, Gambia, Ghana, Guinea, 
Guinea -Bissau, Grenada , Guatemala, Guyana, Republic of South Africa, South Sudan, Georgia, Haiti, 
Honduras, India, Iraq, Jamaica, Cambodia, Cameroon, Cape Verde, Montenegro, Kazakhstan, 
Kenya, Kyrgyzstan, Kiribati,  Colombia, Comoros, Congo, Kosovo, Costa Rica, Democratic People's 
Republic Of Korea , Cuba, Lao People's Democratic Republic , Lesotho, Liberia, Libya, Lebanon, 
Madagascar, Republic Of North Macedonia , Malawi, Maldives, Mali, Marshall Islands, Mozambique, 
Mexico, Micronesia (Federated States Of) , Mongolia, Republic of Moldova, Montserrat, Mauritania, 
Mauritius, Myanmar, Namibia, Nauru, Nepal, Niger, Nigeria, Nicaragua, Niue, Central  African 
Republic, Uzbekistan, Pakistan, Palau, Panama, Papua New Guinea, Par aguay, Peru, Rwanda, 
Russian Federation, Samoa, Sao Tome and Principe, Senegal , Seychelles, Serbia, Sierra  Leone, 
Solomon Islands, Somalia, Sri Lanka, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the 
Grenadines, Sudan, Suriname, Swaziland, Chile,  Tajikistan, United Republic of Tanzania, 
Timor -Leste, Togo, Tonga, Trinidad and Tobago, Tunisia, Tuvalu, Turkmenistan, Uganda, Ukraine, 
Oman, Uruguay, Jordan, Vanuatu, Venezuela (Bolivarian Republic Of) , Yemen, Zambia, Zimbabwe.  
 
V. PROPOSED DATE OF INTRODUCTION OF THE MEASURE  
The measure will enter into force on 26/08/2022. The related Presidential Decree was published in 
the Official Gazette on 27/07/2022.  
 
VI. EXPECTED DURATION OF THE MEASURE  
The expected duration of the proposed measure is three years . 
 
VII.  PROPOSED DATE FOR THE REVIEW  
Not applicable.  
 G/SG/N/8/TUR/20 • G/SG/N/10/TUR/20 • G/SG/N/11/TUR/27  
 
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  VIII.  EXPECTED TIMETABLE FOR PROGRESSIVE LIBERALIZATION OF THE MEASURE  
In order to induce adjustment, the proposed measure will be subject to liberalization on a regular 
basis following its imposition, thereby ensuring that there is a strong incentive for domestic 
producers to undertake progressively the necessary restructuring and adjustment programs. The 
proposed measure is to be progressively liberalized as indicated in item IV above.  
 
IX. INFORMATION REL ATING TO THE EXTENSION OF A SAFEGUARD MEASURE  
Not applicable.  
 
__________